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February 8-9, 2006
Meeting Summary
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Table of Contents
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| I. Record of Attendance |
| II. Clinical Laboratory Improvement
Advisory Committee (CLIAC) - Background |
| III. Call to Order and Committee
Introductions
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| IV. Agency Updates and Committee Discussion
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| V. Presentations and Committee Discussion
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| VI. Committee Discussion of Future Agenda
Items
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| VII. Public Comments
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VIII. Adjourn
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| Record of Attendance |
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| Committee Members Present
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| Dr. Lou Turner, Chair |
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Mr. Kevin Kandalaft |
| Dr. Kimberle Chapin |
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Dr. Patrick Keenan |
| Ms. Joeline Davidson |
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Dr. Michael Laposata |
| Dr. Kathy Foucar |
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Dr. Dina Mody |
| Ms. Merilyn Frances |
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Dr. Valerie Ng |
| Ms. Paula Garrott |
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Dr. Barbara Robinson-Dunn |
| Dr. Peter Gomatos |
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Dr. Jared Schwartz |
| Dr. Carol Greene |
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Dr. David Smalley |
| Dr. Lee Hilborne |
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Dr. Thomas Williams |
| Dr. Anthony Hui |
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Dr. Jean Amos Wilson |
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| Executive Secretary
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| Ex Officio Members |
| Dr. Thomas Hearn, CDC |
| Ms. Judith Yost, CMS |
| Dr. Steven Gutman, FDA |
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Liaison Representative - AdvaMed
Ms. Luann Ochs, Roche Diagnostics Corporation
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| Centers for Disease Control and Prevention
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| Ms. Nancy Anderson |
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Dr. Adam Manasterski |
| Dr. Rex Astles |
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Ms. Leslie McDonald |
| Ms. Pam Ayers |
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Dr. James Pirkle |
| Ms. Carol Bigelow |
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Ms. Anne Pollock |
| Dr. D. Joe Boone |
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Dr. Eunice Rosner |
| Ms. Diane Bosse |
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Ms. Andrea Scott |
| Dr. Roberta Carey |
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Dr. Shahram Shahangian |
| Dr. Bin Chen |
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Mr. Darshan Singh |
| Ms. Debbie Coker |
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Dr. Balasubr Swaminathan |
| Ms. Carol Cook |
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Dr. Julie Taylor |
| Ms. Stacey Cooke |
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Mr. Howard Thompson |
| Mr. David Cross |
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Ms. Pam Thompson |
| Ms. Christine Ford |
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Ms. Leigh Vaughan |
| Ms. MariBeth Gagnon |
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Ms. Glennis Westbrook |
| Ms. Sharon Granade |
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Mr. Mark White |
| Mr. James Handsfield |
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Dr. Laurina Williams |
| Dr. Harvey Holmes |
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| Dr. Devery Howerton |
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Ms. Joyce Witt |
| Dr. Dan Jernigan |
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Ms. Darlyne Wright |
| Dr. Lisa Kalman |
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| Dr. Rima Khabbaz |
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| Dr. John Krolak |
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| Dr. James Lange |
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| Dr. Ira Lubin |
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| Mr. Kevin Malone |
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| Department of Health and Human Services
(Agencies other than CDC)
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| Ms. Minnie Christian (CMS) |
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Mr. Cornell Prodan (CMS)
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| Mr. James Cometa (CMS) |
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Mr. Benjamin Snyder (CMS) |
| Dr. Elliot Cowan (FDA) |
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Ms. Kathy Todd (CMS) |
| Ms. Sandra Farragut (CMS) |
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Ms. Harriet Walsh (CMS) |
| Ms. Daralyn Hassan (CMS) |
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Ms. Gwendolyn Williams (CMS) |
| Ms. Cecilia Hinkel (CMS) |
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Ms. Cheryl Wiseman (CMS) |
| Ms. Fran Lehr (CMS) |
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Mr. Gary Yamamoto (CMS) |
| Ms. Raelene Perfetto (CMS) |
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| In accordance with the provisions of Public Law 92-463, the meeting was open to
the public. Approximately 30 public citizens attended one or both days of the
meeting. |
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Clinical Laboratory Improvement Advisory Committee
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The Secretary of Health and Human Services is authorized under Section 353 of
the Public Health Service Act, as amended, to establish standards to assure
consistent, accurate, and reliable test results by all clinical laboratories in
the United States. The Secretary is authorized under Section 222 to establish
advisory committees.
The Clinical Laboratory Improvement Advisory Committee (CLIAC) was chartered in
February 1992 to provide scientific and technical advice and guidance to the
Secretary and the Assistant Secretary for Health regarding the need for, and
the nature of, revisions to the standards under which clinical laboratories are
regulated; the impact on medical and laboratory practice of proposed revisions
to the standards; and the modification of the standards to accommodate
technological advances.
The Committee consists of 20 members, including the Chair. Members are selected
by the Secretary from authorities knowledgeable in the fields of microbiology,
immunology, chemistry, hematology, pathology, and representatives of medical
technology, public health, clinical practice, and consumers. In addition, CLIAC
includes three ex officio members, or designees: the Director, Centers for
Disease Control and Prevention; the Commissioner, Food and Drug Administration;
the Administrator, Centers for Medicare & Medicaid Services; and such
additional officers of the U.S. Government that the Secretary deems are
necessary for the Committee to effectively carry out its functions. CLIAC also
includes a non-voting liaison representative who is a member of AdvaMed and
such other non-voting liaison representatives that the Secretary deems are
necessary for the Committee to effectively carry out its functions. Due to the
diversity of its membership, CLIAC is at times divided in the guidance and
advice it offers to the Secretary. Even when all CLIAC members agree on a
specific recommendation, the Secretary may not follow their advice due to other
overriding concerns. Thus, while some of the actions recommended by CLIAC may
eventually result in changes to the regulations, the reader should not infer
that all of the Committee's recommendations will be automatically accepted and
acted upon by the Secretary.
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CALL TO ORDER - INTRODUCTIONS/FINANCIAL DISCLOSURES
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Dr. Lou Turner, Chair, Clinical Laboratory Improvement Advisory Committee
(CLIAC), welcomed the Committee members and called the meeting to order. Dr.
Robert Martin, Director, Division of Public Health Partnerships (DPHP),
National Center for Health Marketing (NCHM), Coordinating Center for Health
Information and Service (CoCHIS), Centers for Disease Control and Prevention
(CDC), and Executive Secretary, CLIAC, thanked the members for their dedication
of time and expertise. All members then made self-introductions and financial
disclosure statements relevant to the meeting topics.
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AGENCY UPDATES AND COMMITTEE DISCUSSION
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Centers for Disease Control and Prevention (CDC) Update
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Coordinating Center for Infectious Diseases (CCID) Reorganization, including
Division of Laboratory Systems (DLS)
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Addendum A
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Dr. Robert Martin, Director, DPHP, NCHM, CDC, announced the Division has
returned to its original name (Division of Laboratory Systems [DLS]) and is
transitioning from CoCHIS to CCID. In the proposed realignment of CCID, DLS
will be in a newly created center within CCID, National Center 4 (NC-4), which
is not yet named. This move will bring DLS in closer alignment with
laboratories at CDC. Dr. Martin introduced Dr. Rima Khabbaz, currently the
Director of the National Center for Infectious Diseases (NCID) and the future
director of the proposed NC-4. She explained the proposed realignment of CCID,
briefly discussed the focus of each center, and gave short biographies of the
new center directors.
Committee Discussion
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A Committee member asked if marketing would still be aligned with DLS in the
agency's reorganization. Dr. Martin explained, while NCHM is the component of
CDC's organizational structure emphasizing communication and partnership
between the private and public health sectors, the alignment of DLS with CCID,
and its crosscutting activities, will allow interaction between DLS and other
CDC laboratories, infectious disease or otherwise.
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One member inquired if the bioterrorism laboratory was in the same area as DLS,
which seemed like an excellent move. Dr. Martin replied the Bioterrorism
Preparedness and Response Program is also part of the proposed NC-4.
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A member requested clarification on how DLS will bring in expertise for the
diverse areas of concern to CLIAC since the focus of CCID is on infectious
diseases. Dr. Martin answered there is no organizational structure at CDC that
is broad enough to accommodate all laboratory specialties. Therefore, that has
always been an issue regardless of where DLS has been located at CDC. However,
DLS has the ability to bring in needed expertise when areas of a particular
discipline are being discussed. Dr. Khabbaz added other programs that span the
healthcare system are also housed in the proposed NC-4 with DLS and part of the
commitment to the reorganization is to work across CDC on such programs.
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Marketing Good Laboratory Practices for Waived Testing -
Update
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Addendum
B
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Ms. Sharon Granade, Health Scientist, Laboratory Practice Standards Branch (LPSB),
DPHP, NCHM, CDC, presented an update of the Division's activities surrounding marketing
CLIAC's recommended Good Laboratory Practices (GLP) for Waived Testing Sites. She
gave a brief background of the development of the recommendations, which were published
in the Morbidity and Mortality Weekly Report (MMWR): Reports and Recommendations.
Reviewing CLIAC's suggestions for marketing, she noted the importance of disseminating
the GLP to a wide audience using a variety of channels. Immediately after publication
in the MMWR, CDC sent announcements with links to the full document via e-mails and
listservs to laboratories, laboratory and medical professional organizations, and
colleagues. By asking these associations to share the information, large numbers of
waived test users can be reached. Ms. Granade named the websites and professional
publications where the GLP have been referenced to date and mentioned potential new
channels for distribution. Future marketing considerations include customizing
materials for target audiences, using focus groups or surveys for feedback, and
collaborating with target groups to provide information at their professional meetings
and develop training materials.
Committee Discussion
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One member asked if the CMS Certificate of Waiver (CW) studies could be used
to measure the success of the GLP recommendations and if the CW studies or
implementation of the GLP have been tied to any of the major payers' reimbursement
to laboratories. Ms. Yost replied CMS follows up with laboratories where issues
have been found to determine whether education, including the GLP recommendations,
has led to sustained improvement. She stated she was not the right person to answer
the payment question.
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Several members complimented the MMWR GLP document and commented on the positive
impact such recommendations will have on improving the skills of those performing
waived testing, particularly in the point of care setting, rapid HIV testing sites,
and healthcare training programs. They emphasized the need for the recommendations
to focus on and be written for various targeted audiences.
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Food and Drug Administration (FDA)
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Addendum
C
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Waiver Guidance Update
Dr. Steven Gutman, Director, Office of In Vitro Diagnostic Device Evaluation
and Safety (OIVD), Center for Devices and Radiological Health (CDRH), FDA, provided an
update on the status of the "Draft Guidance for Industry and FDA Staff: Recommendations
for Clinical Laboratory Improvement Amendments of 1988 (CLIA) Waiver Applications."
The 40 comments received during the public comment period are being analyzed and the
guidance modified. The document is a high priority with the end of 2006 as the target
date for issuance of the Final Draft and moving forward with the Proposed Rule. Dr.
Gutman also commented on OIVD's current work including reviewing CDC's polymerase
chain reaction (PCR) assay for influenza A/H5, a series of glucose meter recalls,
and publication of notice, not guidance, of informed consent paperwork reduction.
Committee Discussion
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Summary of 11/30/05 Blood Products Advisory Committee (BPAC) Session:
Approaches to Validation of Over-the-Counter (OTC) Home-Use HIV Test Kits
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Addendum D
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Dr. Elliot Cowan, Chief, Product Review Branch, Division of Emerging and
Transfusion Transmitted Diseases, Office of Blood Research and Review, Center
for Biologics Evaluation and Research, FDA, summarized the November 2005
meeting of FDA's Blood Products Advisory Committee (BPAC) on validation
approaches for OTC home-use HIV test kits. He gave an overview of FDA's
considerations from the beginning of home-use blood collection kits in
1986 to the 1995 Federal Register notice revising FDA guidance for
specimen collection kits for HIV antibody testing. The 1995 notice pertained
only to specimen collection and did not address kits for home-use testing of
specimens for evidence of HIV infection. Dr. Cowan then reviewed the changes
since 1995 in HIV testing including approval of rapid HIV tests. He discussed
the approval requirements, standards, and sales restrictions for rapid HIV tests
and emphasized sales restrictions apply to rapid HIV tests. Noting the recurring
themes in benefits and risks associated with OTC home-use HIV test kits, he
pointed out additional issues of obtaining a test result without a supplemental
test, the cost factor for those who need the test most, and potential conflict
with state and/or federal health reporting requirements.
Dr. Cowan reviewed highlights of the speakers' presentations at the November
2005 BPAC meeting. Topics included the proposal for an OTC rapid HIV antibody
test using oral fluids, suggested changes in HIV testing practices and counseling
recommendations, and an explanation of the role of quality systems in diagnostic
testing. Dr. Cowan also detailed the discussion of the psychological and social
issues associated with HIV testing and OTC home-use tests and presented an overview
of FDA's OTC review process including human factors considerations. In addition,
he described the open public hearing comments regarding home-use HIV test kits.
Three issues were presented to BPAC for discussion: the appropriateness of FDA's
previously established rapid HIV test sensitivity and specificity criteria for rapid
OTC home-use HIV tests, the clinical studies necessary to validate the safety and
effectiveness of these OTC tests, and the proposed content and adequacy of informational
materials. Dr. Cowan commented BPAC did not express opposition to the concept of an
OTC home-use HIV test kit; rather the BPAC discussion centered on what conditions
would be needed to validate a home-use kit approval. He reviewed the next steps for
evaluating the proposed studies to support the approval of OTC home-use HIV tests and
the status of reports of reduced specificity with OraQuick oral fluid testing, noting
the latest information on this issue from CDC's February 6, 2006, webcast,
"Investigation of Reports of Excessive False-Positive Oral Fluid Rapid HIV Tests" at
www.retroconference.org/2006. In conclusion,
Dr. Cowan encouraged the audience to attend and participate in the next BPAC meeting on
March 10, 2006, and reminded those planning to make public comments to register to speak.
He assured the Committee FDA would consider all comments and recommendations.
Committee Discussion
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A Committee member inquired about efforts to avert false positives in
low-prevalence areas. Dr. Cowan replied part of FDA's challenge in clinical
trials will be to show that any risks are mitigated.
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Members discussed manufacturers need to carefully design the test performance
criteria, emphasizing the importance of valid positive predictive values and
inclusion of this information in the package insert. One member asked if there
is existing evidence showing that intended users read the package insert; is
there a way to ensure that the user understands what is meant by a "preliminary
positive" result. Dr. Cowan responded that predictive values vary greatly
depending on the population and emphasized that it is the manufacturer's
responsibility to address this. Based on studies, FDA would ascertain whether
the test is designed appropriately.
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Another member expressed psychosocial concerns when HIV testing does not include
face-to-face counseling. The member also had concerns about the validity of
clinical trials since they would most likely not reach the population for which
the tests were intended. Another member questioned whether current gaps in HIV
testing needs are sufficient to warrant the challenges of OTC home-use testing,
such as the ramifications of false positive results, lack of counseling, and loss
of public health reporting. The member also expressed concern over the possibility
of additional infectious disease testing outside of a controlled environment.
In contrast, a CLIAC member made statements in support of OTC home-use HIV testing
related to test performance, reduction of perinatal transmission, anonymous access
to counseling, and destigmatization of the disease. This member's only concern was
for possible off-label use of tests approved for OTC home-use HIV testing in the
professional (healthcare) setting, e.g., physician offices.
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A Committee member, noting that the percentage of HIV-positive persons who are
unaware of their status has remained constant over the past five years, questioned
whether OTC HIV testing would decrease this percentage. Dr. Cowan responded the key
to address this concern is to determine why people do not know they are infected.
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The CLIAC Chair concluded the discussion by noting the potential difficulty in guiding
individuals into the healthcare system to receive treatment if home testing is offered.
She also questioned if the test kits would be affordable to the population most likely
to use home testing.
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Centers for Medicare & Medicaid Services (CMS)
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Addendum
E
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Ms. Judy Yost, Director, Division of Laboratory Services (DLS), Survey and Certification
Group (SCG), CMS, updated the Committee on the Partners in Laboratory Oversight's
membership, accomplishments, and current and future projects. These projects include
efforts to improve the consistency of quality policies among the accreditation
organizations, exempt states, and CMS; and to clarify the laboratory director's
responsibilities. She discussed the Quality Control (QC) for the Future activities,
including the Clinical and Laboratory Standards Institute (CLSI) manufacturers'
guidance document on risk management (anticipated publication by end of 2006) and
the CLSI guidance to laboratories for developing and customizing QC protocols based
on the manufacturer's risk management information and the laboratory's unique
environmental factors. Ms. Yost also reviewed the status of the Government
Accountability Office's (GAO) audit and the new CLIA Automated Complaint Tracking
System (ACTS) that CMS is initiating at the end of March.
Ms. Yost continued by updating the Committee on CLIA statistics and the status of the proposed
rule for genetic testing. Commenting on Certificate of Waiver (CW) studies, Ms. Yost stated although
this is the final year of the current approval, CMS has submitted a proposal to continue the studies
indefinitely. She noted the number of CW laboratories continues to grow and education facilitates
improved performance.
In conclusion, Ms. Yost introduced the topic of cytology proficiency testing (PT).
In 2005, the first year of national cytology PT, 98% of laboratories enrolled and 91%
of individuals taking the test passed. No one will fail this year and no action will
be taken unless the laboratory does not enroll in the PT program. Failure of the
laboratory to enroll in a PT program will result in fines, revocation of the
laboratory's cytology certificate, and/or denial of cytology Medicare payments.
Committee Discussion
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Ms. Luann Ochs, AdvaMed Liaison to CLIAC, congratulated CMS on providing
more information for laboratory directors and inquired as to the types of
complaints CMS was compiling in their complaint-tracking database. Ms.
Yost replied the complaints vary and come from physicians, employees, and
others. She explained CMS considers everything and all complaints will go
into the tracking system to be counted. Breakdowns will be provided
according to complaint source, resolutions, and whether the complaint was
verified.
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A Committee member inquired about how the system would work if CMS
received a complaint concerning an accredited laboratory. Ms. Yost explained
CMS would notify the accrediting agency immediately and the decision would be
made as to whether CMS, the accrediting organization, or both would follow up
with a survey. The new tracking system will improve the coordination between
CMS and the accrediting agencies
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Another member asked if CMS was considering creating a type of patient safety
organization where issues that did not reach the complaint level could be reported.
Ms. Yost stated CMS has preliminarily discussed working with the Institute for
Quality in Laboratory Medicine (IQLM) to combine quality requirements into the
broader scope of patient safety. She noted the Veterans' Administration (VA)
and accrediting organizations are considering other patient safety initiatives.
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One member congratulated CMS on the progress made towards publication of the
proposed rule for genetic testing, and commented that the 2003 changes in CLIA
regulations pertaining to genetic testing have been very useful to the genetics
community. The member welcomed the opportunity to comment on the proposed rule
when it was published, particularly with the increased migration of esoteric
testing with complex interpretations into more routine laboratory environments.
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A member asked what follows if a laboratory fails to enroll in cytology PT or if
an individual fails the testing. Two members asked for more specifics regarding
laboratories that had not signed up for the cytology PT program and if some were no
longer offering gynecological cytology services. Ms. Yost replied that no one will
fail the test this year while CMS evaluates the ramifications and effects of the PT
program. She stated CMS has identified laboratories that have not yet signed up, but
has not yet identified the reasons why they have not done so. Ms. Yost explained
CMS has encouraged consolidation of laboratories that perform small numbers of
gynecologic testing. She added cytology PT applies only to gynecological testing
sites and original CMS data for laboratories that conduct cytology testing did not
distinguish between laboratories performing gynecological cytology testing and
non-gynecological testing. CMS has now culled those doing only non-gynecological
testing from their list of laboratories subject to cytology PT.
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PRESENTATIONS AND COMMITTEE DISCUSSION |
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National Cytology Proficiency Testing (PT) Update
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Addendum
F
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Ms. Cheryl Wiseman, Health Insurance Specialist, DLS, SCG, CMS, updated the Committee
on national cytology proficiency testing (PT) through 2005. She briefly reviewed the
cytology-specific language of the 1988 CLIA statute, listed the approved cytology PT
providers for 2005 and 2006, and outlined the testing format before discussing
preliminary results of the 2005 testing. The results as of January 31, 2006,
included both the national Midwest Institute for Medical Education (MIME) program
and the State of Maryland program. She compared the year-end statistics with those
of August 2005, noting their similarity. She added that the four locum tenens
failures included two cytotechnologists and two primary screening pathologists and
noted 141 individuals chose not to attempt a second test after failing the initial
test. The data included comparison of the pass rates of primary screening
cytotechnologists with primary screening pathologists. She also compared the initial
statistics from MIME to the State of Maryland's figures in 1990 and 1995.
Ms. Wiseman then described a comparison of test scores broken down by slide preparation
type, and reviewed the automatic failure rates. She advised CLIAC of proposed
legislation, H.R.4568, which has passed the House and is now in a Senate subcommittee
and could influence cytology PT. Ms. Wiseman concluded by discussing current CMS
activities, including convening a CLIAC cytology PT workgroup. Additionally, CLIAC
will convene for an interim 2006 meeting for the Committee to consider the workgroup's
findings and formulate recommendations to the Secretary, Department of Health and Human
Services, to facilitate rule making.
Committee Discussion
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Commenting on the reduction in numbers of primary screening pathologists since
1995, one member asked if CMS had information on what kind of practices the
primary screening pathologists were in. The member stated an organization was
recommending against such practice by pathologists. Ms. Wiseman replied CMS has
the names and locations of these pathologists, but all the information regarding
the reduction in numbers has not yet been analyzed. She assured the Committee
CMS would make every effort to get the information to them when it is available.
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The same member inquired about the outcomes of challenges made by examinees of
their PT results, specifically about notifying those who may have failed due to
problematic slides and about correcting any possible wrongful test failures. Ms.
Wiseman said these data were among five or six data sets that have been requested
but not yet received. The member commented on how important such matters are to
examinees, both economically and professionally, adding that confidentiality in
the event of failures is not assured with on-site testing in small laboratory
situations. Ms. Wiseman replied the testing programs were required to have
procedures in place to manage any technical or scientific issues that arise.
Further, CMS has made confidentiality a high priority but there are cases where
individuals have voluntarily announced their test failure. She reassured the
Committee that CMS was in the process of working to provide them with data
related to cytology PT.
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Another member asked if there were objections to persons with multiple failures
having to stop reviewing slides. No CLIAC members stated objections, but a member
expressed concern at the possibility of failure being linked to improperly validated
slides. Ms. Yost noted slides associated with testing failures are closely monitored
and this information is recorded. The Chair noted that in-house mandatory monitoring
of technologist screening competency is required, stating laboratories should be
detecting weak performance prior to a PT failure. She added the current CLIA review
process does not, however, require similar performance review, i.e., 10% random
rescreen, for pathologist screeners.
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A member asked if examinees should contact CMS directly when procedural problems are
not addressed by testing proctors. Ms. Wiseman agreed they should and added CMS is
investigating such complaints.
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A member questioned whether 100% slide review is instituted if an examinee fails
the PT or withdraws before attempting the third retest. The Chair noted her
laboratory would institute 100% reviews before reaching that point.
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Process for Revising Regulations for Cytology Proficiency Testing
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Addendum
G
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Dr. Devery Howerton, Chief, Laboratory Practice Evaluation and Genomics Branch, and Acting
Chief, LPSB, DPHP, NCHM, CDC, provided an overview and discussion of the process for
revising the CLIA cytology proficiency testing regulations. She described the process
being used to solicit comments and defined expectations for appropriate input. She
discussed both general and cytology-specific proficiency testing requirements, detailed
the necessary steps for publication of a proposed rule, and provided a timeline for
revising the regulations and developing a final rule. Dr. Howerton concluded by
announcing the CLIAC Cytology Workgroup would meet in Atlanta March 28-29, 2006.
In addition, she suggested potential dates for an interim CLIAC meeting in 2006.
Committee Discussion
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In response to a question regarding the workgroup membership, Dr. Howerton
provided the following details and preliminary agenda for the two-day meeting:
- Workgroup Chair: Diane Solomon
- Workgroup Members: Pathologists - George Birdsong, Diane Davey, William
Frable, Ronald Luff, Dina Mody, and Stephen Raab; Cytotechnologists - Gwen Brown,
William Crabtree, Paul Elgert, Deanna Iverson, Jacalyn Papillo, and Thomas Scheberl
- Process for Invited Consultants and Comments: On day one, invited representatives
from proficiency testing providers and new technology manufacturers will participate as
consultants to provide information and comments for workgroup consideration.
Additionally, invitations will be sent to the professional organizations for
distribution to their memberships, allowing an opportunity for individual comment.
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Update on American Society for Microbiology (ASM) Survey of QC Failures with Microorganism Identification Systems
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Addendum
H
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Dr. David Sewell, Pathology and Laboratory Medicine Service, Veterans Affairs Medical
Center, and Department of Pathology, Oregon Health Sciences University, provided an
update on ASM's final survey results of QC failures experienced by users of microbiology
identification (ID) systems. He reminded CLIAC that CLIA requires laboratories test
each substrate or reagent in microbial ID panels for positive and negative reactivity
with each batch, lot number, and shipment. He stated ASM was asked to collect QC data
from microbiology laboratories to assist CLIAC in substantiating the need for a change
in the CLIA QC requirements for microbial ID systems. Explaining the survey instrument,
Dr. Sewell reviewed the general and QC related questions; discussed the number of
surveys sent, response rate, and demographics of the responding laboratories;
summarized the survey results; and thanked the CLIAC and CDC staff who helped with
the survey instrument. Dr. Sewell concluded by recommending use of the Clinical and
Laboratory Standards Institute (CLSI) consensus process to determine appropriate QC for
these systems, indicating ASM is currently in discussion with CLSI to develop a QC
protocol.
Committee Discussion
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A member inquired about a timeline for specific QC recommendations. Dr.
Sewell said a proposal will be presented to CLSI at their April meeting and
CLSI will then form a committee if document development is deemed feasible.
Dr. Hearn added that once a proposal is accepted by CLSI, the timeline should
be 22 months at maximum.
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A member expressed concern this issue would extend to affect multiplex
genetic analysis, cautioning a large number of controls would be expensive;
synthetic supercontrols are used in multiplex genetic testing to assure effective
QC while using fewer wells. The member wondered if synthetic supercontrols might
also be effective in future multiplex microbiologic testing development.
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In response to the question of the study design permitting evaluation of
using fewer organisms to detect QC failures effectively, Dr. Sewell responded
affirmatively, saying the tests failing QC were attributable to either an
organism or substrate failure. Additionally, he noted that of the seven lots
failing QC, six were from different systems, indicating no one test system was
identified to be a problem.
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Discussion among several members focused on requiring manufacturers to include
appropriate data on the performance of individual lots and /or certain biochemicals
to help reduce the amount and frequency of QC. Dr Sewell agreed and pointed out
requiring manufacturers to provide specific performance data with media had resulted
in reduced QC requirements for media.
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In answer to a question regarding reduced QC requirements affecting new test systems
entering the market, Dr. Sewell acknowledged this as an important concern that is
not being addressed. He stated that data is available for only 52 of the 72
microbiology test systems on the market, questioned whether sampling of new and
infrequently used systems was adequate, and suggested this issue needs to be examined
by a consensus group. Another member pointed out manufacturers, through Good
Manufacturing Practices (GMP), must guarantee test system quality, and GMP should be
continued with new systems entering the market.
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CLIAC members agreed a consensus group including manufacturers, users, and regulatory
agencies should address many of the issues raised, and the next step should be to
present a proposal to develop QC protocol for microbiology ID test systems to CLSI at
their April meeting.
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Coordinating Council for the Clinical Laboratory Workforce (CCCLW)
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Addendum
I
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In response to the Committee's request for a report on workforce issues, Ms. Joeline
Davidson, Administrative Director, Laboratory Services, West Georgia Health Systems,
and CLIAC representative to the CCCLW, updated the Committee on CCCLW activities.
She prefaced her presentation by reviewing a list of the Council's participants and
acknowledging their contribution to the Council's activities. She went on to provide
an overview of the four major elements of the strategic plan, the CCCLW participant
lead for each element, and the continuing and future activities of CCCLW advocating
for the laboratory profession and targeting laboratory workforce issues and shortages.
Ms. Davidson concluded by presenting the U.S. Bureau of Labor and Statistic's
Laboratory Workforce projections for 2012, emphasizing the need for new insights to
address recognized issues that continue to contribute to the growing shortages in the
laboratory workforce.
Committee Discussion
CLIAC members agreed the CCCLW's strategic plan targeting retention and recruitment
was correctly focused and long overdue. Several members recounted their experiences
with workforce shortages and others provided examples of how their institutions were
trying to address workforce shortages. Views expressed by the Committee members
included the following:
- Laboratorians must be promoted within their institutions and their
professional image must be improved
- Skills and competencies of existing personnel need to be better managed to
include better utilization of the associate degree technician
- Workforce shortages in all areas of healthcare are much higher in the
underserved populations and worse than the recent studies seem to indicate
- Medical technologists in some areas of the country are seeing pay
increases but this needs to occur nationally and include all laboratory
personnel
- Higher work loads and fewer staff to perform the work is resulting in increased "burn out"
- Better technologies and the development of molecular testing is increasing automation and reducing personnel needs even in the more complex testing areas
- Laboratory education programs and curricula must be more flexible and more structurally diverse
- Diverse, poorly monitored on-the-job training programs are increasing the number of under-qualified individuals performing high complexity testing
- More incentives (scholarships, grants, stipends, sign-on bonuses) are required to recruit and retain laboratory personnel
- Graduates from laboratory science programs are going into more lucrative fields instead of practicing in hospitals and clinical settings
- Younger professionals want more flexible work schedules and are less willing to seek employment that requires weekend/holiday commitment
- Colleges are not attracting students into the science fields
Ms. Davidson concurred, indicating that the existing data as well as her experience
support the Committee's views. She also pointed out recent graduates often feel
over-qualified for routine bench testing and quickly become bored. She suggested
more challenging, higher educational levels, e.g., clinical doctorate as proposed by
several organizations to fill consultative and other high-level laboratory roles,
might revitalize the profession. She emphasized the National Accrediting Agency for
Clinical Laboratory Science (NAACLS) is now addressing changes in educational levels
and curriculum requirements for laboratory training programs in an effort to narrow the
gap with a quality laboratory workforce. She agreed with several members that, without
required licensure, it is difficult to attract quality candidates and to promote the
laboratory profession. In addressing retention in laboratories, Ms. Davidson cautioned
that laboratory science programs marketing their programs as "stepping stones" to other
areas could be detrimental to the profession's retention efforts. In a final comment,
one member referred to a recent article listing medical technology among the growing
healthcare career opportunities for college graduates as a "ray of hope" amidst other
work force issues.
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Diagnostic Detectives Toolkit
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Addendum
J
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Dr. Robert Martin, Director, DPHP, NCHM, CDC, provided CLIAC with a snapshot of a
resource tool developed by the Michigan Association of Laboratory Science Educators
with support from a CDC/Michigan Department of Community Health grant and available
on medtech@msu.edu for teachers and students.
He cited the CD ROM tool kit as an
example of the outcome of a public/private collaboration addressing the laboratory
workforce shortage. The tool kit uses "day in the life" presentations, case studies,
interactive web links, games, and other activities to promote careers in laboratory
sciences to pre-college/college audiences. He recognized other collaborative efforts
addressing workforce shortage issues, emphasizing there is no single solution to the
complex issues associated with laboratory workforce shortages. Dr. Martin concurred with Ms.
Davidson that innovative approaches to both retention and recruitment issues must be
developed and implemented to stem the increasing vacancy rates observed in the
laboratory science professions.
Committee Discussion
CLIAC applauded the CD ROM, seeing it as an excellent recruitment tool for
pre-college audiences and a creative vehicle for promoting the diverse career
paths open to laboratory science program graduates. Several members voiced concern
that too much focus was on recruitment tools and too little on innovations to address
the more difficult issues contributing to low retention rates. CLIAC concurred as
follows:
- Funding is needed to support successful, large scale marketing and public relations efforts
- Strengthening public school science curricula and promoting well-trained science teachers is critical
- Retention issues, e.g., pay and professional recognition, must be addressed
- Healthcare institutions and professional organizations need to develop and
support local programs promoting careers in laboratory science, e.g., shadowing
and internships, and educational workshops for teachers and students
- Studies correlating quality laboratory practice with improved patient outcomes could effectively promote recognition and give value to the profession
- Quality laboratory medicine can be promoted though patient testimonials
- Expanding healthcare institution and college/university partnerships will support and promote laboratory training curricula
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Enhancing Connectivity Between Public Health and Clinical Laboratories
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Addendum
K*
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Dr. Robert Martin, Director, DPHP, NCHM, CDC, introduced the topic of enhancing
connectivity between federal laboratories, public health laboratories, and clinical
laboratories. He described CDC's strong, long-time partnership with the Association
of Public Health Laboratories (APHL), whose mission is to promote the role of public
health laboratories in support of national and global objectives. In addressing the
need for strengthening connectivity between public health and clinical laboratories,
Dr. Martin provided examples of how CDC's realigned goals and strategic imperatives
necessitate and encourage stronger partnership between federal, public, and private
laboratories. He gave a conceptual overview of a national laboratory system,
describing it as a link between federal laboratories, state and local public health
laboratories, and hospital, independent and physician office laboratories. Dr. Martin
explained that four states were involved initially in helping to articulate what state
public health laboratories could do to increase connectivity with clinical laboratories.
He went on to provide a detailed explanation of the formative evaluation conducted to
determine the process required to expand the national laboratory system concept to all
50 states, which included case studies of the initial four state demonstration sites, a
survey of state public health laboratory directors, and a survey of a sample of clinical
laboratories. Dr. Martin discussed factors identified in the survey of clinical
laboratory directors and managers that would increase reliance by clinical laboratories
on state public health laboratories as a source of information and thus improve their
connection. He recounted recent natural disasters and the emergence of a virulent
influenza A strain that have highlighted the importance of coordinating efforts among
all laboratory constituents. Dr. Martin concluded by introducing the Laboratory
Outreach Communication System (LOCS), intended to build a volunteer communications
infrastructure for the exchange of laboratory-related information between CDC and
the broad laboratory community. LOCS will utilize multiple routes of communication
to focus on dynamic issues such as changes in regulations, standards or practices,
urgent public health issues, and disaster relief and will help enhance CDC's existing
communication structures to reach various audiences.
*Note: The addendum was revised from material provided in the Committee's notebooks to reflect last minute updates by the presenter.
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The Role of Public Health Laboratories
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Addendum
L*
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Dr. Katherine Kelley, Director of Public Health Laboratories, Connecticut Department of Public
Health (CPHL), and President, Association of Public Health Laboratories, used the CPHL's
customers, services, and performance standards as an example of the role of public health
laboratories. She indicated the primary customers of state public health laboratories
are communities consisting of other state agencies, local public health departments,
clinical laboratories, federal agencies, and many public health partners. Dr. Kelley
explained how public health laboratories support numerous programs and provide a wide
scope of services, both clinical and environmental, and stressed that the expanding
role of public health laboratories requires implementation of an integrated data
management system for information sharing in real time. Dr. Kelly stated the priority
for public health is development of performance standards and accreditation of public
health laboratories through processes encompassing laboratory improvement and
regulations, policy development, emergency preparedness, public health research,
management and leadership skills, strategic planning, and stronger communications.
Dr. Kelly emphasized the future must include improved collaboration among clinical and
public health laboratories with real-time information sharing to achieve positive
health outcomes.
Committee Discussion
The discussion following Dr. Martin's and Dr. Kelly's presentations covered examples of
problems experienced by Committee members in their relationships with public health
laboratories as well as examples of successful collaborations that improved laboratory
services. Major issues identified included the variability of public health resources
allocated by states, lack of standardization of services, communications between the
public health and clinical laboratory communities, and workforce issues.
-
Committee members gave examples of their experiences with successful
collaborations such as an agreement for management services of a public
health laboratory using independent and university laboratories. This
resulted in the formation of a workgroup consisting of regional
hospitals, independent laboratories, and physician office laboratories
to create manuals, compile contact information, and recruit volunteers
for the strategic national stockpile. The LOCS was also cited as an
example of a successful communications network within the laboratory
community.
-
One member asked Dr. Kelly about the crucial roles and interactions
of public health laboratories and agricultural and veterinary
laboratories. Dr. Kelley acknowledged these as critical relationships
and described CPHL's partnerships with other state agencies
(environmental protection, agriculture), including barriers to be
addressed. Other members mentioned the collaborative efforts of public
health, universities, and government agencies, such as that between a
Michigan state university and several state agencies to produce a web
site on emerging infectious diseases for public and laboratory use.
-
Suggestions from Committee members included incorporating more expertise
when addressing prevention-based genetic testing and contacting medical
programs to incorporate public health system education into the core
curriculum to address variability among medical schools, residencies,
and state public health programs.
-
Regarding barriers to standardization efforts, Dr. Martin summarized
that leadership is needed at the federal, state, public, and private levels
to encourage collaboration among the states, and recommendations from CLIAC
would be helpful both now and in the future.
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Emergency Preparedness Connectivity
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Addendum
M
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Dr. Harvey Holmes, Deputy Chief, Laboratory Response Branch, Bioterrorism Preparedness
and Response Program, NCID, CDC, presented an overview of the Laboratory Response
Network (LRN) and its activities relative to communicating with state public health
laboratories. He discussed a 2004 report from the Office of the Inspector General,
"States' Laboratory Response Programs for Bioterrorism: Level A Laboratory
Participation," that cited three key vulnerabilities and made recommendations to
improve communications on resources and policies, improve emergency communications,
enhance training for Sentinel laboratories, and provide criteria that define Sentinel
laboratories. Dr. Holmes reported a committee consisting of the APHL, CDC, National
Laboratory Training Network, and state public health laboratories developed definitions
for both the Sentinel laboratory and the basic capacity clinical laboratory
classifications. Additionally an American Society for Microbiology Sentinel Guideline
Workgroup produced criteria for the basic and advanced Sentinel laboratories. Clear
identification of these laboratories provides opportunities for better training and
communications with the LRN.
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Outbreaks and Public Health Responses
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Addendum
N
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Dr. Daniel Jernigan, Acting Associate Director for Epidemiologic Science, Division of
Healthcare Quality Promotion, NCID, CDC, presented the components of outbreak
investigations (detect, confirm, characterize, survey, intervene, prevent) as part of
public health on a local and international level. He provided examples from several
CDC investigations that illustrated these components and emphasized the relationships
between laboratory and epidemiologic activities as part of the public health response.
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The Role of the Clinical Laboratory and the Public Health
Laboratory in Foodborne Diseases Surveillance, Outbreak Investigations and Prevention
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Addendum
O*
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Dr. Balasubr Swaminathan, Team Leader, Laboratory Units, Foodborne and Diarrheal Diseases
Branch, Division of Bacterial and Mycotic Diseases, NCID, CDC, reviewed the scope of
CDC's public health surveillance for foodborne diseases and its efforts to expand the
reporting of infectious agents in all 50 states and some additional countries outside of
the United States. CDC programs that are important for foodborne disease surveillance,
monitoring, and prevention include the National Antimicrobial Resistance Monitoring
System (NARMS), FoodNet (surveillance, burden and trend monitoring), PulseNet
(foodborne pathogens subtyping for outbreak detection and investigation), and
Electronic Foodborne Outbreak Reporting (eFORS) for reporting foodborne outbreaks to
CDC using the internet. The success of these programs depends on timely reporting of
notifiable cases and timely submission of the pathogens to state or local public health
laboratories for identification and control of outbreaks. Cooperation with clinical
laboratories is an essential part of this process, since they supply the isolates to
the public health laboratories.
Dr. Swaminathan concluded by describing challenges to surveillance activities arising
from traditional laboratory isolation of foodborne pathogens being replaced by
non-culture testing. The resultant absence of pathogenic isolates available for
surveillance studies compromises recognition of prevalent strains and new pathogens
causing foodborne diseases. Although CDC supports the use of non-culture assays,
the continuation of culture and identification from positive specimens remains a
critical element in disease surveillance, control, and prevention.
*Note: The addendum was revised from material provided in the
Committee's notebooks to reflect last minute updates by the presenter.
Committee Discussion
- Dr. Martin began the discussion by asking the speakers if there were new
technologies that would help address the potential public health impact of
having fewer isolates available for epidemiologic studies. Dr. Swaminathan
indicated microarrays would be a possibility in the future. For the short
term, he suggested communicating with clinical laboratories about the new
molecular methods and the consequences of not culturing positive specimens.
For the long term, public health should prepare for new molecular testing by
having communication networks in place to share ideas, techniques, and reagents.
Dr. Jernigan added monitoring some diseases is becoming more difficult without
isolates for testing. He acknowledged the expansion of rapid test methodologies
in response to a growing patient safety movement and suggested this could be
balanced by pursuing the epidemiologic need for isolates as an equally important
patient safety concern.
-
Members reiterated this epidemiologic dilemma already exists because resistant
organisms are not being identified by molecular tests. Another member suggested
CLIAC broaden the perspective beyond infectious diseases to include issues of cancer
and genetic testing, noting concerns with transferring to some new technologies and
losing the ability to conduct older methods that may be more expensive and
labor-intensive, yet more accurate.
-
Dr. Martin requested CLIAC help develop an agenda to address and broadly
examine the issues discussed (disease detection/epidemiologic surveillance/
determination of antibiotic resistance in the absence of isolates, validation
of technology transfers), bringing stakeholders, including manufacturers, into
the discussion.
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Biomonitoring
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Addendum
P
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Dr. James Pirkle, Deputy Director for Science, Division of Laboratory Sciences, National Center
for Environmental Health (NCEH), CDC, introduced the Division's infrastructure, instrumentation,
and methodologies used in their biomonitoring (biological monitoring) program for toxic
industrial chemicals. He defined the biomonitoring role as measuring the internal dose
of environmental toxicants in people and explained the difficulty and assumptions made
in establishing toxicant exposure information and health effects data. Dr. Pirkle used
lead data from the 1970's and 1980's to demonstrate how quality human data can reduce
the uncertainty in health risk assessments and how environmental modeling predictions
without biomonitoring data may lead to false conclusions. He also showed how the
continued biomonitoring of human blood lead levels revealed health effects at lower
exposure levels than originally established, resulting in CDC considering lowering the
lead exposure limits. Dr. Pirkle discussed biomonitoring of other specific toxicants,
how a toxicant's metabolic pathway is used to determine the appropriate sample type,
and the role NCEH has played in supplying data and assessing a toxicant's health risk
to the U.S. population. He encouraged the CLIAC to view the "Third National Report on
Human Exposure to Environmental Chemicals," at www.cdc.gov/exposurereport, stressing
its value to public health. Dr. Pirkle closed by emphasizing the critical importance
of identifying at-risk populations and reducing the health effects of exposures to
environmental toxicants.
Committee Discussion
-
When asked if background levels of pesticides were highest in food or water, Dr.
Pirkle responded that, although not well established, it is generally thought to
be higher in food because of large amounts imported from areas where pesticides
are not regulated. He reminded the audience to always wash fruits and vegetables
before consuming.
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Referring to the graph of cotinine levels (non-tobacco users in households with no
smokers), another member asked why serum levels did not reach zero. Dr Pirkle
explained that trace amounts of cotinine in foods, e.g., tomatoes and iced tea,
inhibit the correlation of cotinine levels lower than .005ng/mL to tobacco smoke
exposure.
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One member asked for clarification of where Dr. Pirkle's laboratory fit within
the CDC organizational structure. Dr. Pirkle gave a brief description of the
reorganized CDC then added an open invitation to CLIAC members to tour their new
facilities at the Chamblee campus.
-
A member expressed curiosity regarding the impact of the Health Insurance
Portability and Accountability Act (HIPAA) on acquiring and testing human samples
in a public health laboratory. Dr. Pirkle replied that HIPAA impacted their testing
about 30% of the time.
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Influenza Laboratory Diagnosis and Surveillance: Enhancing Connectivity Between Public Health and Clinical Laboratories
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Addendum
Q
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Dr. Peter Shult, Director, Communicable Diseases Division and Emergency Laboratory
Response, Wisconsin State Laboratory of Hygiene, presented "Influenza Laboratory
Diagnosis and Surveillance: Enhancing Connectivity between Public Health and Clinical
Laboratories." Introducing statistics on the annual impact of influenza, he stressed
pandemic influenza preparedness activities are becoming a national priority and
provided the website for strategic national plans: www.pandemicflu.gov. Emphasizing
surveillance is the core of preparation and response to any pandemic flu plan, he
detailed the objectives of influenza surveillance and highlighted laboratory
contributions to good surveillance. Acknowledging the expanding role of the clinical
laboratory in the diagnosis of influenza, Dr. Shult reviewed influenza test methods
and time required for results and discussed the advantages and concerns surrounding
rapid test methods. He expressed concern that widespread use of rapid testing could
have a negative effect on surveillance because using these methods might not allow
retention of influenza isolates for strain typing, which is the cornerstone of the
vaccine system. Dr. Shult encouraged public health laboratories to engage rapid test
sites as key partners in an effort to encourage state public health and clinical
laboratories to work together. He reviewed biosafety requirements for rapid antigen
testing, suggesting clinical laboratories provide biosafety training for their
satellite laboratories to ensure testing is performed safely. Dr. Shult concluded
by saying all laboratories need to start prioritizing now to prevent testing
capacities being overwhelmed in the event of an influenza pandemic.
Committee Discussion
-
Members agreed with the issues presented by Dr. Shult, adding that staffing,
supplies, and test volume capacity are also critical concerns for laboratories
preparing for a pandemic response.
-
One member stated rapid influenza testing has resulted in under-reporting case
numbers due to lack of confirmation by other test methods and shared a sample
collection method that provides sufficient sample for both a rapid test and further
testing. The same member asked Dr. Shult how he encourages rapid test sites to send
test results and specimens to the public health lab and agreed with his concerns
regarding biosafety practices in rapid testing facilities. Dr. Shult reaffirmed the
importance of encouraging rapid test sites to communicate with public health
laboratories to maintain active epidemiologic surveillance. He indicated LRN
coordinators in his state played an important role in improving inter-laboratory
communication and in encouraging rapid testing laboratories to collect samples for
confirmatory testing. He referred CLIAC to the appendix of the CDC pandemic plan for
additional discussions on these issues and reemphasized the need for training
clinicians and laboratorians. With respect to positive and negative predictive
value in rapid influenza testing, Dr. Shult stressed the importance of educating
users to the concept that a negative predictive value is more useful during the
influenza "off season" than it is during the peak season.
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SPECIAL PRESENTATIONS
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The Committee recognized the contributions of six retiring members whose terms will end June 2006:
- Dr. Kimberle C. Chapin
- Dr. M. Kathryn Foucar
- Dr. Peter J. Gomatos
- Dr. Anthony N. Hui
- Dr. Michael Laposata
- Dr. Jared N. Schwartz
On the occasion of her recent retirement from 33 years of dedicated and exemplary
federal service, Ms. Rhonda Whalen, Chief, Laboratory Practice Standards Branch,
Centers for Disease Control and Prevention, was presented with a commemorative plaque
from the Clinical Laboratory Improvement Advisory Committee in recognition of her
outstanding contributions and commitment to the promotion of high quality laboratory
testing and practices.
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PUBLIC COMMENTS
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Dr. David Sewell, American Society for Microbiology
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Addendum
R
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Ms. Janie Robertson, American Society for Cytotechnology
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Addendum
S
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Ms. Robin Stombler, Institute for Quality in Laboratory Medicine
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Addendum
T
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Dr. George Birdsong, American Society of Cytopathology
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Addendum
U
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Dr. Mark Stoler, American Society for Clinical Pathology
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Addendum
V
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ADJOURN
Dr. Turner thanked the members and partner agencies for their support and participation. The following
reflects the recommendations and outcomes from this meeting:
- A workgroup has been formed and will meet on March 28-29, 2006, to address potential changes to the cytology proficiency testing regulations
- CLIAC will convene in June 2006 to consider the Cytology Proficiency Testing Workgroup's report and make recommendations for changes in cytology proficiency testing regulations
- The Committee requested the formation of a workgroup comprised of stakeholders including epidemiologists, clinical laboratories, public health laboratories, industry, and government to
examine and broadly address the myriad issues related to the impact of rapid testing technology on clinical laboratories, public health laboratories, and epidemiology
Dr. Turner announced the remaining 2006 CLIAC meetings are scheduled for June 20-21 and September 20-21, and adjourned the Committee meeting.
I certify this summary report of the February 8-9, 2006, meeting of the Clinical Laboratory Improvement Advisory Committee is an accurate and correct representation of the meeting.
| Lou Flippin Turner, Dr.P.H., CLIAC Chair |
Dated: 4/26/2006 |
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This page last reviewed: 5/8/2006
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